Meadoux v. State, 2010 Tex. Crim. App. LEXIS 1568

Meadoux, age 16 at offense, was charged with capital murder for killing two men and burning their bodies in Bexar County (Jan 24, 2007).
Indicted Oct 3, 2007; trial held Aug 4, 2008; jury convicted Meadoux as charged; punishment set at life imprisonment without parole.
On direct appeal, Meadoux challenged the LWP sentence as applied to a juvenile capital offender under the Eighth Amendment.
Court of Appeals rejected Meadoux’s Eighth Amendment challenge; this Court granted discretionary review to resolve the issue.
Court held that the national consensus does not clearly favor abandoning LWP for juvenile capital offenders and that the punishment is justified by moral culpability, retribution, and incapacitation, though it does not promote deterrence or rehabilitation.
Meadoux’s dissent argued that Texas’s statutory changes and historical treatment show LWP for juveniles is unconstitutionally harsh.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether life without parole for a juvenile capital offender violates the Eighth Amendment	Meadoux contends LWP is grossly disproportionate for juveniles.	State argues no categorical Eighth Amendment ban; national consensus does not oppose LWP for juveniles.	No; court upholds LWP for juvenile capital offenders as not grossly disproportionate.

Graham v. Florida, 130 S. Ct. 2011 (2010) (categorical challenges to juvenile LWOP require proportionality analysis)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles have lesser culpability; cannot be treated as worst offenders)
Kennedy v. Louisiana, 554 U.S. 407 (2008) (murderous offenses by juveniles require careful proportionality reflection)
Atkins v. Virginia, 536 U.S. 304 (2002) (national consensus and moral culpability in capital punishment context)
Tison v. Arizona, 481 U.S. 137 (1987) (retribution and culpability considerations in severe punishments)
Penry v. Lynaugh, 492 U.S. 302 (1989) (historical sentencing considerations in Texas; legislative changes noted)